Investment Property & The GloBE Rules
Whilst the treatment of investment property for financial accounting purposes is important when determining the GloBE treatment, of even more importance are any differences between the financial accounting treatment and the domestic tax treatment.
Blended CFC Regimes and Avoiding Unrelievable CFC Taxes
Top-up taxes under a QDMTT are added to covered taxes of a CFC but only for the purposes of calculating the allocation of Blended CFC Taxes. The way the rules operate is aimed at minimising unrelievable CFC taxes under Blended CFC Regimes. Read more.
The 4 Different Jurisdictional Effective Tax Rates Under the GloBE Rules
The clarifications and additions to the Commentary to the Pillar Two GloBE Rules provided by the OECDs Administrative and Safe Harbours Guidance, means that there are now up to four jurisdictional effective tax rates (ETRs) that may need to be calculated to determine the impact of the GloBE Rules.
Differences Between Domestic CFC Regimes and the GloBE Rules That Allow Cross-Jurisdictional Blending
The definition of CFC taxes that are restricted in the GloBE rules is much narrower than under many domestic CFC regimes. In this article we look at this issue.
Group Financing Companies and Pillar Two
MNE groups should pay careful attention to any group financing companies in light of the Pillar Two Rules. In this analysis we look at the impact of Pillar Two for both general GloBE and QDMTT purposes.
Spain Gazettes a Law to Amend the Basque Economic Agreement for Global Minimum Tax Provisions
Law 3/2025, of 29 April, was published in the Spanish Official State Gazette on April 30, 2025. This amends the Economic Agreement with the Basque Country and includes a new Article 20bis for the application of the Pillar 2 Global Minimum Tax.
Cross-Border Deals After Pillar Two
In this article we look at some of the most significant issues to consider including the determination of when and how deals can bring groups within the scope of Pillar Two, specific considerations for private equity funds, differences in GloBE and domestic tax treatment and potential restrictions on post-acquisition transfers.
Corporate Investments and Pillar Two
The Pillar Two GloBE treatment of corporate investments will depend to a large extent on the nature of the activities, the accounting treatment and the ownership interest.
Switzerland Opens Consultation for Applying OECD GIR Provisions
On April 30, 2025, the Swiss Federal Council issued a proposal to amend the Minimum Tax Ordinance to provide for the OECD GIR provisions, as well as some other small amendments.
Japan Issues Regulations for its QDMTT from April 1, 2026
On March 31, 2025, Japan enacted Cabinet Order No. 121 of 2025 and Ministry of Finance Ordinance No. 19 of 2025 to provide further details on the application of Japan’s QDMTT from April 1, 2026.
